Savage v. Commissioner of Social Security

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 5/25/17: Plaintiff may have an extension of time, to and including May 4, 2017, in which to file Plaintiff's Motion for Summary Judgment; Defendant may have an extension of time to June 5, 2017 to file her opposition, if any is forthcoming. Any reply by plaintiff will be due June 26, 2017. (Kaminski, H)

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Steven G. Rosales
Attorney at Law: 222224
Law Offices of Lawrence D. Rohlfing
12631 East Imperial Highway, Suite C-115
Santa Fe Springs, CA 90670
Tel.: [phone]
Fax: [phone]
E-mail [e-mail]

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Attorneys for Plaintiff CARRIE RUTH SAVAGE

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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CARRIE RUTH SAVAGE,
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Plaintiff,
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vs.
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NANCY A. BERRYHILL, Acting
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Commissioner of Social Security,
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Defendant
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) Case No.: 2:16-CV-01591 AC
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) STIPULATION TO EXTEND
) BRIEFING SCHEDULE
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TO THE HONORABLE ALLISON CLAIRE, MAGISTRATE JUDGE OF
THE DISTRICT COURT:
Plaintiff Carrie Ruth Savage (“Plaintiff”) and defendant Nancy A. Berryhill,
Acting Commissioner of Social Security (“Defendant”), through their undersigned
counsel of record, hereby stipulate, subject to the approval of the Court, to extend
the time for Plaintiff to file Plaintiff’s Motion for Summary Judgment to May 4,
2017; and that Defendant shall have until June 5 2017, to file her opposition. Any
reply by plaintiff will be due June 26, 2017.

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As the Court is aware, Counsel suffered the loss of his spouse. Counsel

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simply underestimated how profound his wife's long illness and unfortunate death

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at the young age of 41 would, for lack of better description, break his stride both at

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home and professionally. Counsel has recognized that the continued routine

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request for extension is not tenable moving forward and has crafted a plan to

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alleviate his case load with the assistance of other Attorney’s from his firm. The

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failure to more timely notify the Court of the need for more time was a result of a

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miscommunication within Plaintiff’s Counsel’s firm as to the status of the due

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date.

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Counsel for plaintiff does not anticipate this extraordinary request for more

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time to become the rule and recognizes it is the extraordinary exception and

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sincerely apologizes to the court for any inconvenience this may have had upon it

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or its staff.

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DATE: May 4, 2017

Respectfully submitted,

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LAW OFFICES OF LAWRENCE D. ROHLFING

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/s/ Steven G. Rosales
BY: _________________________
Steven G. Rosales
Attorney for plaintiff CARRIE RUTH SAVAGE

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DATED: May 4, 2017

PHILLIP A. TALBERT
United States Attorney

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*/S/- Jennifer Lee Tarn

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_________________________________
Jennifer Lee Tarn
Special Assistant United States Attorney
Attorney for Defendant
[*Via email authorization]

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IT IS HEREBY ORDERED that plaintiff may have an extension of time, to

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and including May 4, 2017, in which to file Plaintiff’s Motion for Summary

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Judgment; Defendant may have an extension of time to June 5, 2017 to file her

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opposition, if any is forthcoming. Any reply by plaintiff will be due June 26, 2017.

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IT IS SO ORDERED.
DATE: May 25, 2017

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